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COLORADO NAT. BANKSHARES, INC. v. C.I.R.

No. 91-9019.

984 F.2d 383 (1993)

COLORADO NATIONAL BANKSHARES, INC., and Subsidiaries, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Tenth Circuit.

January 25, 1993.

Attorney(s) appearing for the Case

Francis M. Allegra, Tax Div., Dept. of Justice, Washington, DC (Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen, and Jonathan S. Cohen, Tax Div., Dept. of Justice, Washington, DC, with him on the brief), for respondent-appellant.

James E. Bye (William S. Huff, Douglas A. Pluss and Charles B. Bruce, Jr., with him on the brief), of Holme Roberts & Owen, Denver, CO, for petitioner-appellee.

Before McKAY, Chief Judge, and McWILLIAMS, and KELLY, Circuit Judges.

PAUL KELLY, Jr., Circuit Judge.

Commissioner appeals the decision of the Tax Court redetermining deficiencies in taxes paid by petitioner-appellee Colorado National Bankshares and its subsidiaries for the 1982, 1983 and 1984 tax years. The Commissioner alleges that the Tax Court erred in holding that the taxpayer was entitled to an amortization1 deduction under I.R.C. § 167 with respect to core deposit intangibles. We affirm.

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